Aegix Global, LLC

Privacy Policy

Aegix Platform — Safety and Incident Management · Effective April 2026 · Last reviewed 2026-04-30

Aegix Platform — Safety and Incident Management

Authoritative source: This customer-facing policy is derived from doc/compliance/privacy-policy-operational.md, Aegix's internal operational privacy posture. That document is the single source of truth for how the product and backend actually handle personal information. Any discrepancy resolves in favor of the operational policy; Legal updates this document to match.

Harmonization baseline (2026-04-22):

  • Aegix applies the strictest broadly-applicable US privacy standard (CCPA/CPRA) nationwide. A thin state-delta layer in state-privacy-deltas.md handles additional obligations in VA / CO / CT / UT / TX / OR, plus K-12 supplements for NY (§ 2-d / 8 NYCRR 121), IL (SOPPA), NJ (SOPA), NH (RSA 189).
  • K-12 student data is additionally subject to FERPA. Aegix operates as a "school official" under 34 CFR § 99.31(a)(1)(i)(B), formally designated in each LEA contract per runbooks/ferpa-school-official-designation.md.
  • DSAR acknowledgment SLA is 5 business days; full response ≤ 45 calendar days; NY § 2-d DSARs respond within 30 calendar days. Procedure: runbooks/ccpa-dsar.md.
  • Subprocessor list: subprocessor-list.md. Changes trigger the 30-day LEA advance-notice clock under SDPC v3 Article III + NY EdLaw § 2-d Part 121.3.
  • Cryptographic posture: FIPS 140-3 approved algorithms only, per ADR 098 §1. No long-lived AWS IAM user access keys (workload identity only).

Welcome to Aegix Global LLC ("we," "us," or "our"), operating under various trade names, including Aegix. This privacy notice describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), including when you download and use our Aegix applications (Aegix One, Aegix AIM, and Aegix SMS), interact with the Aegix platform on behalf of an organization that has authorized your account, or engage with us in related ways.

Scope of This Privacy Policy

The Aegix platform serves organizations operating physical sites across multiple sectors — schools and school districts, colleges and universities, healthcare facilities, federal / state / local government agencies, corporate campuses, religious institutions, summer camps, sports and entertainment venues, and similar — that need real-time safety communication, incident management, and emergency-response coordination. The platform consists of three client applications and a shared services layer: Aegix One provides personal safety notifications, check-in status, and communication tools. Aegix AIM serves on-site staff and emergency responders (law enforcement, fire, EMS, and PSAP / public-safety dispatch personnel) with incident management, indoor/outdoor mapping, and real-time coordination. Aegix SMS handles site administration, integrations with the authorizing organization's existing systems (including, where applicable, K-12 Student Information Systems), reunification management, visitor management, and on-site administrative functions. All three applications share a common platform infrastructure, data layer, and security controls.

Universal privacy posture (applies regardless of sector)

This Privacy Policy applies to all end users of the Aegix platform regardless of the sector in which the authorizing organization operates. Aegix processes personal information in compliance with the California Privacy Rights Act ("CPRA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Connecticut Data Privacy Act ("CTDPA"), the Texas Data Privacy and Security Act ("TDPSA"), the Oregon Consumer Privacy Act ("OCPA"), and other applicable US state comprehensive privacy laws. Geolocation tied to identified individuals and other sensitive personal-information categories are processed under the heightened protections those laws require. Data minimization, purpose limitation, security-of-processing, and breach-notification commitments described later in this Policy apply to every Authorized Customer relationship.

Sector-specific applicability

In addition to the universal posture, the Aegix platform supports sectors with specific regulatory obligations. The sections that follow describe sector-specific privacy commitments that apply only when the authorizing organization (the "Authorized Customer") falls within the relevant sector:

K-12 Authorized Customers

The provisions in this section apply when the Authorized Customer is a K-12 Local Education Agency, charter network, private K-12 school, or other K-12-serving organization that processes student records and education records.

FERPA Compliance

Aegix Global LLC acts as a "school official" under the Family Educational Rights and Privacy Act (FERPA, 20 U.S.C. § 1232g) and is authorized to access, process, and maintain education records on behalf of Local Education Agencies (LEAs). Our relationship with each LEA is governed by a written Student Data Privacy Agreement (SDPA) that specifies:

COPPA Compliance for Users Under 13

Aegix platform may be used in school environments where students under age 13 are present. Aegix complies with the Children's Online Privacy Protection Act (COPPA, 15 U.S.C. § 6501-6506) as follows:

NY Education Law § 2-d Compliance

For students in New York State schools, Aegix platform complies with Education Law § 2-d, which restricts the collection and use of personally identifiable information:

To the extent Aegix platform incorporates adaptive or customized learning features, use of Student Data and Teacher Data for such purposes is permitted under NH Exhibit G, Item 8 and is not considered a commercial or marketing use. Any adaptive learning features operate solely to improve educational outcomes within the scope of the contracted services.

Aegix does not use radio frequency identification (RFID), Bluetooth Low Energy (BLE) beacons, near-field communication (NFC), or any similar radio-frequency technology to identify, locate, monitor, or track students or teachers. (NH Exhibit G, Item 12)

Data Minimization and Student Privacy

Aegix applies data minimization principles to student information:

Restrictions on Student Data Use

Aegix platform is committed to strict limitations on how student data is used:

Student and Family Privacy Rights

Parents, guardians, and eligible students have the following rights regarding student data:

Student Data Privacy Agreement (SDPA)

Aegix Global LLC has executed Student Data Privacy Agreements with Local Education Agencies in the following states: Massachusetts, Maine, Colorado, Illinois, Iowa, Missouri, Nebraska, New Hampshire, New Jersey, New York, Ohio, Rhode Island, Tennessee, Vermont, Virginia, and Washington. Each SDPA specifies:

Higher-Education Authorized Customers

The provisions in this section apply when the Authorized Customer is a college, university, or other post-secondary educational institution.

Government Authorized Customers

The provisions in this section apply when the Authorized Customer is a federal, state, local, tribal, or military government agency.

Healthcare Authorized Customers

The provisions in this section apply when the Authorized Customer is a hospital, clinic, health system, accredited care provider, or other healthcare organization.

Other Site-Operating Authorized Customers

The provisions in this section apply when the Authorized Customer is a corporate, religious, summer-camp, sports / entertainment venue, or other site-operating organization not falling within the K-12, higher-education, government, or healthcare sectors above.

Safety Protocol Compliance Reporting

Aegix platform maintains comprehensive logging and reporting of safety protocol compliance. This includes:

Location Services and Digital 911 Routing

The Aegix Applications use device location to provide indoor and outdoor mapping, incident reporting, reunification check-in, and — for organizations that have enabled it — automated routing of alerts to public-safety dispatch services. Location is treated as "sensitive personal information" under the California Privacy Rights Act and as analogous "sensitive data" under the Virginia, Colorado, Connecticut, Texas, and Oregon comprehensive privacy laws, and is processed accordingly.

Current collection.

Digital 911 Routing.

When an organization has enabled the Aegix Digital 911 Routing integration, an Aegix alert is forwarded to a certified public-safety dispatch provider for routing to the appropriate Public Safety Answering Point ("PSAP") or Emergency Communications Center. The current dispatch provider is RapidSOS; see the Subprocessor List for details.

Planned expansions.

The features and controls described in this section may change as Aegix releases new versions of the Applications. Aegix anticipates introducing the following capabilities in future releases, in addition to the current Digital 911 Routing data flow:

Before introducing any of the above, Aegix will (a) update this Privacy Policy; (b) refresh the corresponding Apple App Store "App Privacy" and Google Play "Data Safety" disclosures to match what the Applications actually do; (c) update the Subprocessor List and provide subscribing LEAs with the 30-day advance notice required under SDPC v3 Article III and NY Education Law § 2-d Part 121.3 to the extent those provisions are triggered by the expanded data category; and (d) provide in-Application notice and the operating-system permission prompts required for any expanded location-collection mode before that mode begins.

Website Visitors (aegix.global)

This section describes Aegix's data handling for visitors to the Aegix marketing website at https://aegix.global, separate from the platform / Application data flows described elsewhere in this Privacy Policy. The Aegix marketing website is a WordPress-hosted public-facing site used for marketing, product information, lead capture, and trust-center publication.

What we collect from website visitors. When you visit aegix.global, we collect the following categories of information:

Third parties that receive website-visitor data. Through the cookies listed in the Cookie Statement, the following third parties may receive personal information from your visit to aegix.global:

CCPA / CPRA "sharing" notice. Under the California Privacy Rights Act and analogous state laws (Virginia VCDPA, Colorado CPA, Connecticut CTDPA, Texas TDPSA, Oregon OCPA, and others), Aegix's use of advertising cookies (Google Ads _gcl_au, Meta Pixel _fbp) constitutes "sharing" of personal information for cross-context behavioral advertising. You have the right to opt out of this sharing. To exercise that right:

Visitor-data retention. Server logs are retained for 90 days for security and operational purposes, then aggregated. Form-submission data is retained for the duration of the relationship plus 7 years (or shorter where required by applicable law) for sales, audit, and tax-record purposes. Cookie retention is described in the Cookie Statement.

Children. The Aegix marketing website is not directed to children. Aegix does not knowingly collect personal information from website visitors who are children under 13 outside of an LEA-administered enrollment context. The Aegix Applications (One, AIM, SMS) are used by K-12 students under the LEA's parental-consent and FERPA "school official" framework described elsewhere in this Privacy Policy; that framework does not apply to anonymous visits to the marketing website.

Distinct from platform data flows. Data collected from your visit to aegix.global is not linked to any student record, education record, or LEA-administered platform account. Aegix does not combine website-visitor cookies with platform-user account data.

NIST SP 800-53 Rev 5 Alignment

Aegix platform is designed in accordance with privacy controls from NIST SP 800-53 Rev 5 (Appendix J - Privacy Controls):

Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information. The following sections describe those rights.

What Categories of Personal Information Do We Collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected
A. Identifiers Contact details, real name, alias, postal address, telephone or mobile number, unique personal identifier, online identifier, IP address, email address, account name YES
B. Personal information (Cal. Civ. Code § 1798.80(e)) Name, contact information, employment history (for staff users provisioned by an LEA) YES
C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin (when included in roster data imported by an LEA's SIS) YES, where included in LEA-provided rostering data; not collected by Aegix from end users directly
D. Commercial information Transaction history, purchase history, payment information NO (Aegix does not collect end-user payment information; LEA billing is handled outside the platform)
E. Biometric information Fingerprints, voiceprints, facial recognition templates NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, interactions with our and other websites, applications, systems, and advertisements YES
G. Geolocation data Device location during active use of safety features YES
H. Audio, electronic, sensory, or similar information Images, video, or call recordings created in connection with incident reporting, reunification, or emergency-response coordination YES
I. Professional or employment-related information Job title, role, department, work history (for staff users provisioned by an LEA) YES, where included in LEA-provided rostering data
J. Education information Student records and directory information processed under FERPA on behalf of the LEA, including roster data, reunification status, incident-report context tying a student to an event, and other student-tied operational data YES — Aegix processes Education Information as a "school official" under FERPA 34 CFR § 99.31(a)(1)(i)(B), governed by the executed SDPA with each LEA
K. Inferences drawn from collected personal information Inferences drawn from any of the above to create a profile or summary about an individual's preferences and characteristics NO
L. Sensitive personal information (CPRA category) Geolocation precise enough to identify a student's room or position; Education Information tied to identified students; account credentials YES — Aegix processes geolocation tied to identified users during active alerts and Education Information tied to identified students; treated as "sensitive personal information" under CPRA and as analogous "sensitive data" under VCDPA, CPA, CTDPA, TDPSA, OCPA, and applicable K-12 supplements

California Residents - CCPA Privacy Notice

California residents have specific rights under the California Consumer Privacy Act (CCPA):

Colorado Residents - CPA Privacy Rights

Colorado residents have specific rights under the Colorado Privacy Act (CPA):

Connecticut Residents - CTDPA Privacy Rights

Connecticut residents have specific rights under the Connecticut Data Privacy Act (CTDPA):

Utah Residents - UCPA Privacy Rights

Utah residents have specific rights under the Utah Consumer Privacy Act (UCPA):

Virginia Residents - VCDPA Privacy Rights

Virginia residents have specific rights under the Virginia Consumer Data Protection Act (VCDPA):

How Can You Contact Us About This Notice?

If you have questions or concerns about this privacy policy, please contact us at:

Email: privacy@aegix.global

Mail: Aegix Global LLC, 94 Lone Hollow Dr., Sandy, UT 84092, United States

How Can You Review, Update, or Delete Your Data?

To request access, correction, or deletion of your personal information, please visit aegix.global/data-request. For student data requests, families should contact their school district's data privacy coordinator.

Document Version: 2.0 (Enhanced with K-12 Education Data Processing)

Last Updated: April 2026

Next Review: April 2027

Appendix: Vendor Compliance Documentation References

The following vendor documentation provides supporting evidence for the compliance claims and technical controls referenced in this document. These resources should be reviewed periodically to ensure alignment with current vendor certifications and capabilities.

Amazon Web Services (AWS)

Note: AWS compliance reports (SOC 2 Type II, ISO 27001) are available for download through AWS Artifact in the AWS Management Console. Contact the CPTO for access credentials.